2. How Dietary Folic Acid Intakes Were Calculated
2.1 Food vehicles for First Review
At Draft Assessment, ‘all bread-making flour’ was selected as a food vehicle for incorporating folic acid into foods due to the high consumption of products assumed to contain bread-making flour as an ingredient by the target group. Following consultations, the mandatory fortification of folic acid in ‘bread’, rather than bread-making flour, was proposed and modelled for Final Assessment.
At First Review, FSANZ was asked to review the fortification vehicle selected with a view to mandating flour for bread-making as the food vehicle for Australia to minimise the regulatory
burden on industry and regulators. For New Zealand, the mandatory fortification food vehicle remained as ‘all bread’ in the First Review.
To determine the range of foods that would be likely to contain added folic acid, it was necessary to determine which foods contain ‘wheat flour for making bread’ (Australia only) and ‘all bread’ (New Zealand only). In Australia, flour for ‘bread-making’ must contain added thiamin. For the purposes of estimating folic acid intakes, foods were assumed to contain
‘wheat flour for making bread’ if Australian products were labelled as containing added thiamin. Following consultation with the food industry, it was also determined that croissants contain ‘wheat flour for making bread’. For the purpose of estimating folic acid intakes for New Zealand, foods were assumed to be a ‘bread’ if they contain cereal flour, were yeast leavened and were baked (refer to Figure 1a and Figure 1b below).
Figure 1: Definition of folic acid fortified foods for dietary intake assessment purposes a. Australia
Wheat flour for making bread:
Includes all white and wholemeal wheat flour used as an ingredient in commercially
produced plain, fancy, sweet and flat breads and bread rolls, English-style muffins, crumpets, scones, pancakes, pikelets, crepes, yeast donuts, pizza bases, croissants and breadcrumb containing products.
b. New Zealand All Bread :
Includes all yeast-containing plain white, white high fibre, wholemeal, grain and rye bread loaves and rolls that are baked; yeast-containing flat breads that are baked (e.g. pita bread, naan bread); focaccia; bagels (white, wholemeal, sweet); topped breads and rolls (e.g. cheese and bacon rolls); English muffins (white, white high fibre, grain, wholemeal and fruit); sweet buns; fruit breads and rolls; and breadcrumbs.
Excludes steamed breads; breads cooked by frying (e.g. puri/poori); yeast-free breads (e.g.
chapatti, tortilla); gluten-free breads; doughnuts; pizzas and pizza bases; scones; pancakes, pikelets and crepes; crumpets; and bread mixes intended for home use.
2.1.1 Why breads/wheat flour for making bread?
At the start of the Proposal P295 – Consideration of Mandatory Fortification with Folic Acid, FSANZ considered suitable food vehicles for fortification; the initial criteria being that the food had to be consumed by a large proportion of the target group in all socio-economic groups and that is was technically feasible to fortify the food. The proportion of different population groups consuming milks (full and reduced fat), fruit juices, breakfast cereals, yoghurts and soy beverage were examined during the initial investigations as well as bread and bread products. There is no food that is consumed by the target group only and not by other population groups. From the data from the NNS publication National Nutrition Survey Foods Eaten Australia 1995 (McLennan and Podger, 1999) indicate that those food groups consumed by a large proportion of women of child-bearing age are also those consumed by a large proportion of young children (aged 2-3 years). Figures 2a and b show the proportions of 2-3 year old Australian children and 16-44 year old Australian women that consume various foods/food groups.
Figure 2: Percentage of Australian children aged 2-3 years and Australian women aged 16- 44 year old consuming various food types
a. Australian children aged 2-3 years
* Cereal and cereal products includes regular breads and rolls
** Dairy milk includes full fat, reduced, low fat and skim milk
Note: These figures are for foods reported as consumed in the NNS and do not take account of consumption of these foods in recipes e.g. milk used in custard.
b. Australian women aged 16-44 years
* Cereal and cereal products includes regular breads and rolls
** Dairy milk includes full fat, reduced, low fat and skim milk
Note: These figures are for foods reported as consumed in the NNS and do not take account of consumption of these foods in recipes e.g. milk used in custard.
Some foods consumed by a large proportion of the target group were not suitable for fortification for technical reasons, for example fruit, vegetables, meat and their products.
Foods such as fruit juices, yoghurts and soy beverages were not consumed by a high enough proportion of the target group to consider them as effective food vehicles for mandatory fortification. However, two food groups were further investigated: (1) bread and bread products; and (2) milk and milk products.
Fortifying flour with folic acid, in this case bread-making flour, is consistent with international experience of mandatory fortification to reduce the incidence of NTDs. Bread-making flour is an effective and technically feasible food vehicle for mandatory folic acid fortification and bread-making flour (as bread and bread products) is a staple food consumed widely, consistently and regularly by the target population of women of child-bearing age across different socio-economic sub groups (as discussed previously in the Draft Assessment report and the Final Assessment Report). In addition, Australia’s experience with mandatory thiamin fortification provides an opportunity to extend the use of existing infrastructure to the
mandatory addition of folic acid to bread-making flour. In the NNSs, approximately 85% of Australian and 83% of New Zealand women of child-bearing age consumed bread-based foods, as defined previously. Regular breads and rolls were consumed by approximately 76% of women of child-bearing age and by approximately 84% of young children (aged 2-3 years).
Dairy milk and products were originally identified as potential food vehicles as they were consumed by at least 50% of the target group (women of child-bearing age) and it was technically feasible to add folic acid. Approximately 82% of women of child-bearing age consumed dairy milk and 90% of children aged 2-3 years. The proportions of women of child-bearing age and children aged 2-3 years who consumed full fat and reduced/low fat milks and yoghurts were further investigated. In the 1995 NNS, a greater proportion of women aged 16-44 years (38%) consumed reduced/low fat milks in comparison to children aged 2-3 years (10%) while a greater proportion of children aged 2-3 years (84%) consumed full fat milk in comparison to women aged 16-44 years (58%). Further detail can be found in Figure 3 below. Reduced or low fat milks could be a more effective food vehicle for the target group than all milk or full fat milk. Full fat milks were consumed preferentially by young children and in larger relative amounts compared to other foods than for adults, so, were they mandated to be fortified, could potentially place young children at a higher risk of excessive folic acid intake than adults.
Figure 3: Proportion of Australian children aged 2-3 years and Australian women aged 16- 44 years consuming different types of milks (1995 NNS)
More recent data from the Australian Dairy Corporation (ADC) on milk production and sales, the ADC Food Consumption Survey and the Roy Morgan Single Source Survey were also assessed as the retail data on milk sales indicated that there had been a trend towards a decrease in full fat milk sales and an increase in reduced fat/low fat milk sales since 1995 (Australian Dairy Corporation, 2003) (Roy Morgan, 2006a; Roy Morgan, 2006b). The ADC Survey (all ages) data confirm that, for all age groups, a higher proportion of people reported consuming low /reduced fat milk (Australian Dairy Corporation, 2003) than reported in the 1995 NNS. This trend is continuing as indicated by the Roy Morgan Survey data for 2001- 2006 (respondents aged 14 years and over) (Roy Morgan, 2006a). FSANZ is also aware that, in the light of concerns about obesity, the current dietary advice for children aged 2 years and over is that reduced fat milks are suitable for these younger children (National Health and Medical Research Council, 2003). Based on this more recent information, FSANZ considered that reduced fat/low fat milk was not suitable as a food vehicle because it appears these milks are as likely as full fat milk to form a higher proportion of a young child’s diet than an adult’s given the trend toward consuming reduced fat milk at a younger age and would increase the potential risk of excessive folic acid intakes for the 2-3 year and 4-8 year age groups were these milks to be mandatorily fortified with folic acid.
In the 1995 NNS, less than 20% of women aged 16-44 years and children aged 2-3 years reported consuming yoghurts, irrespective of the fat content of the yoghurt. Similar proportions of these two population groups consumed reduced/low fat yoghurts, while a greater proportion of children aged 2-3 years consumed full fat yoghurt in comparison to women aged 16-44 years. Although more recent retail sales data and that from the ADC (Australian Dairy Corporation, 2003) and Roy Morgan (Roy Morgan, 2006a; Roy Morgan, 2006b) surveys indicate the proportion of people consuming yogurt has increased since 1995, it is still less than 40% for the target group but higher for the young children (up to 70%) so that again there would be a risk of excessive folic acid intakes for these latter age groups were full fat yoghurt to be mandatorily fortified with folic acid.